Document oMbBO9Qaz4R9qyzVQZv27Qqmr

.-*9-2 '-. -'4 5 jS' : 7 A L5 3 i V 2 5 i O N To (Name) Division Location Mr. J. L. Myers UCC - Metals Niagara Falls, NY 1 cco Messrs. G. R. Adams W. B. DeAtley T. W. Carmody T. D. Finnigan/G. J. Hanks, Jr. R. F. X. Fusaro/J . J. Sibley. E. W. Kantz/R. G. Beverly 0. J. Malacarne R. W. Rebholz C. C. Smith, Jr. J. W. Whittlesey P. 0. 3QX 579 *4625 ROYAL AVE., NIAGARA FALLS, NEW YORK 14202 ate Originating Dept. February 13, 1980 "Calidria" Asbestos Answering letter date Subject EPA Information Gathering Orders Under Sections 8(a) and 8(d) of TSCA On December 31, 1979 the EPA issued a proposed general order under Section 8(d) of TSCA relating to mandatory submission of health and safety studies. Response date is February 29, 1980. The AIA/NA decided at its Executive Committee Meeting on February 12, 1980 that it would make no substantive response to this proposal. This is based on the facts that the Chemical Manufacturers Association and others are responding in detail and that we cannot identify any issues that are unique to asbestos. The question of a Union Carbide response was discussed recently with Messrs. Sibley and Baumblatt. It was agreed that they would check this out. In view of the AIA/NA position, I plan no action. The EPA is also drafting two general orders under Section 8(a), one specific to asbestos and one covering a wide variety of materials, presumably those in the 8(d) proposal mentioned above. Publication of the proposal is expected in April. A draft of detailed reporting instructions for the asbestos 8(a) order has been obtained from EPA and is attached for your information. It appears to be a research project to fill it out. The EPA is now trying to persuade the AIA/NA that nine companies should volunteer to evaluate the reporting instructions, not actually fill them out. They would like comments on the form, the levels of management that would need to become involved, and the time and costs to fill it out. Since there are only three mining and milling companies in the U.S., I'm sure that we would be one that they would like to have participate. No committments of any kind will be made without prior approval from appropriate UCC management. UCC 003449 ^ O 4. 0